NEW COX FIRST MEDIA PRIVACY POLICY
Effective Date: October 2021
To download this Privacy Policy, click here.
Privacy Policy Scope
Welcome! Thank you for your interest in Ohio Newspapers, Inc. d/b/a Cox First Media, a division of Cox Enterprises, Inc., and our “Affiliates” (other companies within the Cox Enterprises, Inc. corporate family) (collectively “Cox First Media Network”). We respect your privacy when you use our websites, and other online products and services (collectively, the “Sites”).
To see the full text, click on the links. This Privacy Policy applies to your use of any Sites that post a link to this Privacy Policy but does not apply to the privacy practices of entities that Cox First Media Network does not own or control. This Privacy Policy should be read in association with our Terms of Use, which governs the Sites.
You can click on the following links to navigate to the different sections in this Notice.
1. INFORMATION WE COLLECT
2. HOW WE USE THE INFORMATION WE OBTAIN.
3. INFORMATION WE SHARE WITH THIRD PARTIES.
4. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
5. DATA SECURITY AND MONITORING.
6. INTERNATIONAL TRANSFER.
7. CHILDREN’S PRIVACY.
8. ACCESSING AND CHANGING INFORMATION.
9. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.
12. CHANGES TO THIS ONLINE PRIVACY POLICY.
13. CONTACT COX FIRST MEDIA NETWORK.
FULL COX FIRST MEDIA NETWORK PRIVACY POLICY
Thank you for visiting one of the Sites that posts a link to this Privacy Policy which is owned or operated by Cox First Media Network (“we,” “us,” or “our”), including but not limited to www.coxfirstmedia.com. This Privacy Policy applies to the Sites and does not apply to any Affiliate that maintains a separate privacy policy. This Privacy Policy will provide you with information as to how Cox First Media Network collects, uses, and shares information about you, including the choices Cox First Media Network offers with respect to that information, and applies to your use of any of the Sites, regardless of how you access or use it. For certain Sites, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.
By visiting or otherwise using the Sites, you agree to the Sites’ Terms of Use and consent to Cox First Media Network’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of any the Sites. If you do not agree and consent, please discontinue use of the Sites.
1. INFORMATION WE COLLECT
When you use the Sites, we, or Service Providers acting on our behalf, may collect your Personally Identifiable Information (defined herein). This generally happens in one of three ways—you provide us with information, we collect information through automated methods, or we collect information from other sources. There are some situations in which it is necessary for us to collect your Personally Identifiable Information in order to provide a service to you or to meet legal requirements.
A. Information about You that You Provide. You may share certain information when you interact with the Cox First Media Network and/or its Service Providers (defined below). For example, Cox First Media Network collects information when you use or post on the Sites, participate in promotional activities, purchase products or services, provide feedback, or request information from or communicate with Cox First Media Network. We may also ask for your information for special reasons, such as for research or in surveys. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices see Section 4. For more information on Service Provider data collection and practices see Section 3.
Information Cox First Media Network, its Service Providers and/or Third-Party Services collect may include: (1) personal information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number (“Personally Identifiable Information” or “PII”); and (2) non-Personally Identifiable Information (“non-PII”) (i.e., data that is not Personally Identifiable Information under this Privacy Policy), including demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases (“Demographic Information”) and “Deidentified” information (i.e., data where the personally identifiable elements have been modified or removed, or where personally identifiable elements of the data have been rendered non-personally identifiable elements through anonymization, pseudonymization, and/or hashing). Except to the extent required by applicable law, Demographic Information is non-PII. In addition, PII, including, without limitation, Cox First Media Network-Collected PII (defined below), once Deidentified, is also non-PII and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that Deidentified data is not capable of re-identification. To the extent any non-PII, or PII collected outside of the Sites, is combined with PII Cox First Media Network collects directly from you on any Sites (“Cox First Media Network-Collected PII”), Cox First Media Network will treat the combined data as Cox First Media Network-Collected PII under this Privacy Policy.
B. Information Collected Automatically. When you use the Sites, our technology, or that of our Service Providers and/or Third-Party Services, Cox First Media Network has the ability to automatically collect certain types of information about you (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Sites, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Cox First Media Network with Cox First Media Network-Collected PII, Cox First Media Network does not consider Usage Information (including, without limitation, unique device identifiers) to be PII or Cox First Media Network-Collected PII. For more information on Third-Party Services’ data collection and practices see Section 4. For more information on Service Provider data collection and practices see Section 3. For information on choices some of these third parties may offer you regarding automated data collection see Section 9.
The methods that may be used on the Sites to collect Usage Information include:
• Internet usage information: Internet usage information is data about your use of the Sites, such as IP address, browser type, Internet service provider, device identifiers, device advertising identifiers, mobile network, operating system details, date/time stamps, language preferences, referring URLs, length of visits, anonymous traffic data, pages viewed, browsing history, search history, information regarding interactions with our website or advertisements, and related data.
• Information Collected by Cookies and Other Tracking Technologies: Cookies, Web Beacons (also known as “tracking pixels”), Embedded Scripts, Location-Identifying Technologies, Device Recognition Technologies, Recording and Tracking Interactions and Usage, and other tracking technologies currently in use or to be developed in the future (“Tracking Technologies”) may be used to collect information about interactions with the Sites or e-mails, including information about your browsing behavior.
Some information about your use of the Sites and certain third-party services may be collected using Tracking Technologies across time and services and used by Cox First Media Network and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Sites and certain third-party services. See Section 9 regarding certain choices regarding these activities. Cox First Media Network is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 9 so that your consent to encountering them is meaningfully informed.
C. Information Cox First Media Network Collects from Other Sources. Cox First Media Network may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Cox First Media Network-Collected PII. Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of Cox First Media Network with Cox First Media Network-Collected PII, this Privacy Policy is not intended to limit Cox First Media Network’s activities regarding such third-party-sourced information (including PII), and such data will only be treated as Cox First Media Network-Collected PII to the extent it is combined with Cox First Media Network-Collected PII. Cox First Media Network is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.
2. HOW WE USE THE INFORMATION WE OBTAIN.
Cox First Media Network may use information about you, including Cox First Media Network-Collected PII and other PII, for any purposes not inconsistent with Cox First Media Network’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:
3. INFORMATION WE SHARE WITH THIRD PARTIES.
Cox First Media Network may share non-PII, and PII that is not deemed Cox First Media Network-Collected PII under this Privacy Policy (provided that Cox First Media Network is aware of no restrictions of Cox First Media Network’s use, if any), with third parties for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your PII, including Cox First Media Network-Collected PII, to non-PII, including, without limitation, through hashing it or substituting a unique identifier for the PII and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. Cox First Media Network’s sharing of Cox First Media Network-Collected PII is, however, subject to the following:
Cox First Media Network may also share any information about you (including, without limitation, Cox First Media Network-Collected PII) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:
In addition, Cox First Media Network may share your Cox First Media Network-Collected PII (as well as your other PII and your non-PII), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Cox First Media Network assets, or transfer of all or a portion of Cox First Media Network’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
4. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
The Sites may include hyperlinks to websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit PII from you.
Cox First Media Network may use Google Analytics or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help Cox First Media Network analyze how users interact with the Sites. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Sites, compiling statistic reports on the Sites’ activity, and providing other services relating to the Sites activity and other Internet usage.
Cox First Media Network may serve ads tailored to your interests based on your browsing of the Sites and elsewhere on the Internet. Such activities by Cox First Media may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Online Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Sites (i.e., “retargeting”).
In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our databases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our databases and the databases of the third-party services. For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads. If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter.
We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
Cox First Media Network is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Sites, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 9 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Online Interest-based Advertising and analytics.
5. DATA SECURITY AND MONITORING.
Cox First Media Network takes reasonable measures to protect Cox First Media Network-Collected PII (excluding public UGC) from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Cox First Media Network does not guarantee the security of your information collected through the Sites.
To help protect you and others, Cox First Media Network and its Service Providers may (but make no commitment to) monitor use of the Sites, and may collect and use related information including Cox First Media Network-Collected PII to, without limitation, identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Sites; ensure compliance with the Terms of Use [Insert Link] and this Privacy Policy; investigate violations of or enforce these documents; improve the Sites and your Sites experiences, and to protect the rights and property of Cox First Media Network, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through the Sites. If you do not consent to these conditions, you must discontinue your use of the Sites.
6. INTERNATIONAL TRANSFER.
Cox First Media Network is based in the U.S. and the information Cox First Media Network and its Service Providers collect is governed by U.S. law. If you are located in the European Union (EU), European Economic Area (EEA), and/or Switzerland, please note that Cox First Media Network does not intend to offer goods and services (including the Sites) to EU, EEA, or Swiss individuals. If you are accessing the Sites from outside of the U.S., please be aware that information collected through the Sites may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Sites or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including PII, in the U.S. as set forth in this Privacy Policy.
7. CHILDREN’S PRIVACY.
The Sites are intended for a general audience and not directed to children less than 13 years of age and we do not knowingly sell the personal information of Consumers we know are under 16. Cox First Media Network does not intend to collect “personal information” as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personally Identifiable Information”) in a manner that is not permitted by COPPA. If you are under 13, do not provide any Personally Identifiable Information to us. If we obtain actual knowledge that we have collected Children’s Personally Identifiable Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. If you believe your child may have provided us with their Personally Identifiable Information, you can contact us at
coxfirstmediaprivacy@coxinc.com and we will delete their Personally Identifiable Information to the extent required by law.
Any California residents under the age of 18 who have registered to use the Sites, and who posted content or information on the Sites, can also request removal by contacting us at coxfirstmediaprivacy@coxinc.com detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
8. ACCESSING AND CHANGING INFORMATION.
Cox First Media Network may allow you to delete, correct, or update some Cox First Media Network-Collected PII, and potentially certain other information about you by contacting us. Cox First Media Network will make good faith efforts to make requested changes in Cox First Media Network’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Cox First Media Network’s databases (California minors see Section 7) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
9. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.
A. Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to HTML 5 cookies or other Tracking Technologies. Please be aware that if you disable or remove these technologies, some parts of the Sites may not work and that when you revisit the Sites your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Like many online services, Cox First Media Network currently does not alter Cox First Media Network’s practices when Cox First Media Network receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Cox First Media Network is not responsible for the completeness or accuracy of this third-party information.
Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on a website is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the websites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Cox First Media Network is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third-party analytics and advertising providers, see the next section. We may offer tools in connection with the Sites that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Sites.
B. Analytics and Advertising Tracking Technologies. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may opt out of Facebook Custom Audience by logging into your Facebook account and changing your privacy or advertising settings as per Facebook’s opt-out instructions. You may also use your Facebook account settings to unlink your Facebook account from the Site.
For the Sites, you may choose whether to receive some Online Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us related to the Sites and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Online Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Online Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Online Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Cox First Media Network supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Cox First Media Network directly engages to serve you Online Interest-based Advertising will do so as well, though Cox First Media Network cannot guaranty their compliance. Cox First Media Network is not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
C. Communications. You can opt out of receiving certain promotional communications (emails) from Cox First Media Network at any time by, for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. If you would like to completely deactivate your account, please contact us at coxfirstmediaprivacy@coxinc.com. Please note, however, that if you deactivate your account, you will not receive any newsletters from us, and you will not be able to participate in any of our promotions. Even if you opt out of receiving promotional communications, Cox First Media Network may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, Cox First Media Network’s ongoing business relations, or communications related to administrative notices or any communications relevant to your use of the Sites, including communications in the event of a data security event.
D. Cross-Device Data. To learn more about how you can exercise certain choices regarding Cross-device data for Online Interest-based Advertising, see the prior section regarding the DAA’s Online Interest-based Advertising choices.
E. California Residents. At this time, Cox First Media Network does not have “established business relationships” with “customers” as those terms are defined in California’s “Shine the Light” law. California residents may contact us for further information regarding our privacy practices or their rights under the California Consumer Privacy Act by emailing
coxfirstmediaprivacy@coxinc.com.
F. Nevada Residents. Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us at coxfirstmediaprivacy@coxinc.com and register for us to provide you notice in the event we change our practices in the future. If we do, you will have an opportunity to be verified and exercise your opt-out rights. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada contact information.
10. CHANGES TO THIS ONLINE PRIVACY POLICY.
We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of the Sites indicates your consent to the privacy policy posted at the time of use. You are responsible for periodically visiting the Sites and reviewing this Privacy Policy to check for any changes. However, we will not treat your previously collected Cox First Media Network-Collected PII, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
11. CONTACT COX FIRST MEDIA NETWORK.
If you have any questions about this Privacy Policy, please contact Cox First Media Network at coxfirstmediaprivacy@coxinc.com or at:
Cox First Media
Attention: Legal
6205-A Peachtree Dunwoody Road
Atlanta, GA 30328
© 2021 Cox First Media, a division of Cox Enterprises, Inc. All Rights Reserved.